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2021 (9) TMI 252 - AT - Income TaxReopening of assessment u/s 147 - Bogus purchases - whether there was relevant material on which a reasonable person could have formed a requisite belief that income has escaped assessment? - HELD THAT:- As the original return was processed u/s. 143(1). Subsequently, upon receipt of certain information from DGIT (Inv.), it transpired that the assessee made suspicious purchase in A.Ys. 2010-11 & 2011-12. On the basis of said information, Ld. AO formed a belief that assessee would have taken bogus bills in A.Y. 2012-13 also to suppress profits. Another reason of reopening was the fact that there was difference in TDS figures. On the given facts, in our opinion, the presence of this material/information was quite enough to reopen the case and no infirmity could be found in reopening the case of the assessee. The legal grounds, thus raised, stand dismissed. Estimation of income o bogus purchases - Quantum of additions - AR has submitted that similar issue arose in A.Ys. 2010-11 & 2011-12 wherein Ld. AO estimated addition of 15% in set-aside proceedings - Since the same has been accepted by both the sides, similar estimation may be made in this year, concurring with the same and adopting consistent approach in the matter, we direct Ld. AO to estimate the additions @ 15% The balance addition stand deleted.
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